ML20236J800
Text
- _ _ _ _ _ _ _
ys
\\
2
,.y a
o
~
M n.
FEB 2 4 1975 Mr. Charles M. Hardin, Manager Radiation and Product Safety Branch Bureau for Health Services
~
Department for Human Rasources 275 East Main Street Frankfort, Kentucky 40601
Dear Chuck:
This is in responsa to your letter concerning application of Mmvimum Permissible Concentrations (MPC's) and the "as low as practicable" (ALAP) concept to releases of radioactive material from the Maxey Flats waste disposal site.
Each radioactive waste burial site is evaluated and accepted based on the predicted ability of the site geology, hydrology and soil characteristics 3
to retain the buried material at the site. As a precautionary measure, monitoring programs are established at the site to permit early detection of indications of migration of radiometive material from the burial area.
,/ ;-
2he early detection of radioactivity as a result of migration is important
{
i
}
since it indicates that the site geology, Hydrology, etc. may not be i
)
providing confin*= ant of the material as anticipated.- Thus, it is our view that, when evaluating migration of radioactive material, the MPC g
values.should not be used as detection levels or action Ihvels in deter-mining whether migrating radioactivity is acceptable or unacceptable, or l' -
.b whether or not corrective action should be instituted. The MPC values are i
I only useful in assessing the radiation safety and public health aspects cf s
the released radioactivity, and thus the urgency in taking corrective 3
action. Also we do not believe the ALAP concept is applicable here either.
What apesars to be needed is the establishment of action levels, which if exceeded would result in specified measures being taken, e.g. more intensi-
{
's fied monitoring, corrective action, etc. However, once it has been deter-j f mined that radioactive material is migrating from a burial site, we believe
- s benefit-risk concept should be applied in evaluating the various alterna-y i
tive corrective actions that might be taken to minimise such migration. '
[
4
-Sincerely,
}i)m%g%@.[s s
p y
q v.
l
'?g
.'m O d d,c G. Wayne Kerr, Chief-Agreements and Exports Branch j
{.
Division of Msterials and L
Fuel Cycle Facility Licensina.
+
' +- -
g.
n-870B060286 870724
\\
eda rom MINTONB7-235 PDR 4